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2 Paths, 2 Outcomes: DOJ’s Inconsistent Corporate Self-Disclosure Policies

by Josh Hurwit, Greg Goldberg, John Anderson and John Sullivan
December 22, 2025

While the Criminal Division guarantees it "will decline" to prosecute companies that voluntarily self-disclose, cooperate fully and remediate appropriately, US attorney's offices merely promise they "will not seek a guilty plea," leaving open the possibility of NPAs or DPAs. Holland & Hart attorneys Josh Hurwit, Greg Goldberg, John Anderson and John Sullivan explore how this difference affects strategic decisions about where to report misconduct, the advantages of rural USAOs' enhanced understanding of local industries versus Criminal Division certainty, and what the forthcoming single DOJ policy may change.

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NEW FROM CCI PRESS

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CCI Press

‘Bribery Beyond Borders’: How the FCPA Became a Global Anti-Corruption Blueprint

by Severin Wirz
December 2, 2025

The debut book by legal historian Severin Wirz, “Bribery Beyond Borders: The Story of the Foreign Corrupt Practices Act,” is a timely reexamination of the statute’s Cold War origins and modern-day relevance. Published by CCI Press, Wirz’s book arrives as the FCPA nears its 50th anniversary and faces renewed scrutiny from reformers, regulators and multinational corporations alike.

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Compliance

Outsourced Compliance: A Strategic Response to Regulatory Strain

by Lori Weston
July 8, 2025

Regulatory uncertainty and stretched compliance teams are creating new pressures for firms navigating an evolving enforcement landscape, even as the SEC appears to be taking a more targeted approach to violations. STP Investment Services’ head of compliance, Lori Weston, examines how outsourced compliance services can provide immediate access to experienced professionals with regulatory knowledge and operational capacity, while offering the pattern recognition and industry perspective that internal teams may lack time to develop, particularly when paired with regulatory technology solutions.

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